Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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Disallowance of remuneration to directors and relatives under section 40A(2)(b) was deleted because the Assessing Officer did not benchmark the payment against fair market value and relied instead on an earlier-year comparison and an arbitrary 10% increase, despite accepted past scrutiny assessments and undisputed services. The Tribunal also upheld allowance of foreign travel expenditure, finding no Rule 46A breach where the travel details had already been filed and no evidence showed absence of business purpose. The revenue's appeal was dismissed.
Disallowance of remuneration to directors and relatives under section 40A(2)(b) was deleted because the Assessing Officer did not benchmark the payment against fair market value and relied instead on an earlier-year comparison and an arbitrary 10% increase, despite accepted past scrutiny assessments and undisputed services. The Tribunal also upheld allowance of foreign travel expenditure, finding no Rule 46A breach where the travel details had already been filed and no evidence showed absence of business purpose. The revenue's appeal was dismissed.
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